
News stories about
Vermillion County
Vermillion Reports is a news site about Vermillion County, Indiana. Our first article is about Wabash Valley Resource’s carbon sequestration project. We plan to publish articles on other topics. If you would like email notices about new articles, please send your email address to us at vermillionreports@gmail.com
Analysis and Viewpoint: Taking a different look at the law for Wabash Valley Resource’s CO2 project
By Larry Gavin
May 12, 2025
Universal, Indiana, with a population of 281 people in 2023, was at one time the home to coal miners and their families. Now, the coal mines are shuttered and there are yard signs saying, “No CO2.” The signs reflect opposition to a proposed project that would pump millions of tons of liquified carbon dioxide a mile into the ground a short distance away.
Indiana has adopted two different laws that apply to the sequestration and storage of carbon dioxide in underground rock formations. One law applies to a proposed carbon sequestration project to be operated by Wabash Valley Resources (WVR) or its subsidiary and that plans to store carbon dioxide in two rural areas located in Vermillion and Vigo Counties. The law calls WVR’s project a “pilot” project. IC 14-39-1 et seq.
Another law applies generally to all other carbon sequestration projects in Indiana, except WVR’s project. IC 14-39-2 et seq.
There are many differences between the two laws, but one key difference is the manner in which the operators of carbon sequestration projects may secure the right to acquire or use the underground rock formations to permanently store the carbon dioxide, and what rights are taken away from the owners of the surface land as part of that process.
Another important difference is who is responsible if something goes wrong after the injections of carbon dioxide cease.
Important questions include: What justifies treating WVR’s project differently from all other carbon sequestration projects in the state? And, what justifies treating landowners in two small rural areas in Vermillion and Vigo Counties differently from landowners in the rest of the State? This article poses the question: Does the law passed for WVR’s project constitute special legislation in violation of Article 4, Sections 22 and 23 of Indiana’s Constitution?
A. WVR’s Project
1. Burying carbon dioxide
WVR is developing a facility in West Terre Haute, Vigo County, Indiana, to produce 500,000 tons of anhydrous ammonia fertilizer each year. One by-product of the process is carbon dioxide, which WVR plans to capture, liquify, and provide to its subsidiary Wabash Carbon Services LLC (WCS). The liquified carbon dioxide will be transported through underground pipelines to two injection wells, one in Vermillion County and one in Vigo County. WCS will use the wells to inject 1.67 million tons of carbon dioxide into the ground each year for 12 years. So, a total of 20 million tons. The carbon dioxide will be permanently stored in rock formations about 5,000 feet below ground.
WVR projects that the carbon dioxide will migrate underground in a two-mile radius from each well’s bottom point. This is referred to as the “pore area” or the “pore space.” There will be about 2,600 feet of confining rock layers between the stored carbon dioxide and the deepest source of drinking water in the area.
WVR says the project will create jobs, benefit the environment, and provide fertilizer for farms in the region.
2. The draft permits and a meeting at Universal
On July 7, 2023, the U.S. Environmental Protection Agency (Region 5) issued two draft Class VI permits to WVR’s subsidiary Wabash Carbon Services (WCS) to inject carbon dioxide into the ground through wells in Vermillion County and Vigo County. The EPA also gave notice that it would hold a public hearing in Terre Haute on Aug. 10, 2023, and it accepted written comments through Aug. 21.
Some residents organized a meeting with representatives of WVR on Aug. 16, 2023, in Universal, which is just east of the pore area in Vermillion County. About 100 people showed up. Some sought information about the project. But many opposed it, saying the injection and storage of the carbon dioxide might cause earthquakes, infiltrate aquifers and drinking water, escape into the atmosphere and harm both humans and animals, and reduce property values.
Some residents said that there have been earthquakes in the area and that the area is in a seismic zone, and that one of the country’s largest aquifers is atop the proposed pore area in Vermillion County.
WVR’s representatives explained the geology of the area, the manner in which the liquified carbon dioxide would migrate underground, the safety precautions they have taken, and said they consulted with experts in the field in developing the project. The project was safe, they said.
In response to a question why WVR did not place an injection well at its facility in Terre Haute, Rory Chambers, WVR’s executive vice president of operations, said it would have been a “PR disaster, because everybody will go, ‘holy smoke this is under the river. This is awful.’” He said he “intentionally looked for areas that had the fewest landowners, not because, ‘Oh, I can bully these people.’” He said, “If there’s a few mad people here, I can go talk to them and calm them down. My god, if there’s 3,000, I’ll never be able to convince those people.”
Wabash pressed on.
3.Permit issued, but remand on appeal
On Jan.19, 2024, the EPA (Region 5) issued permits that allow WCS to construct and operate the two injection wells. A drawing showing the location of each well and the projected pore areas are shown in the figure below, which is attachment B to the permits.
The EPA’s scope of review is limited and focuses on whether there will be an adverse impact on drinking water. The EPA determined that “the wells meet all requirements for initial approval, including stringent safety measures.” EPA Region 5 Administrator Debra Shore said, “Today’s action will help reduce industrial carbon dioxide emissions that contribute to climate change while protecting nearby communities and essential groundwater resources in Vermillion and Vigo counties.”
During the permit process, the EPA reviewed extensive technical data and received more than 1,000 comments. The EPA made clear in its “Response to Comments,” which it published on the same day it issued the permits, that comments made on 43 different topics were outside the scope of its review, including: “concerns about property values in the area”; “concerns regarding State of Indiana’s legislation for the project (pore space rights, eminent domain, and indemnity to [WVR])”; “concerns regarding the financial compensation to landowners”; and “statements that there are better ways and locations to sequester carbon dioxide.”
Several landowners appealed Region 5’s decisions approving the permits. One issue raised in the appeal was the length of time that WCS would be required to monitor the project after it stopped injecting carbon dioxide into the ground and to provide data to the EPA demonstrating that “the geologic sequestration project does not pose an endangerment to USDW [underground sources of drinking water].” The default period is 50 years, but Region 5 of the EPA reduced the period to 10 years.
On March 3, 2025, the Environmental Appeals Board remanded the permit decisions and directed Region 5 of the EPA to explain the basis for its conclusion that a 10-year post-injection site care period was appropriate, rather than 50 years.
B. Indiana’s Carbon Sequestration Laws
Indiana has enacted laws in 2019, 2022, 2023 and 2025 dealing with the underground sequestration of carbon dioxide:
· In 2019, Indiana adopted a law authorizing WVR’s carbon sequestration project, which was called a “pilot” project. The law applied only to WVR’s project. Senate Bill 442 (2019), IC 14-39-1 et seq.
· In 2022, Indiana adopted a general law applying to all carbon sequestration projects in the state, except WVR’s project. House Bill 1209 (2022), IC 14-31-2 et seq.
· In 2023, Indiana amended the 2019 law authorizing WVR’s project, and it created a new path for WVR to secure the pore areas to store carbon dioxide. Senate Bill 451 (2023), IC 14-31-1 et seq.
· In 2025, the legislature amended the law applicable to WVR’s project in one respect and amended the law applicable to all other projects. SB 457 (2025) and HB 1001 (2025).
These laws provide WVR’s project different or special treatment than all other carbon sequestration projects in the State. The sections below summarize some of the key differences, particularly in the way WVR may obtain the right to use the pore areas for its project and how some landowner rights are restricted. There are other differences as well.
Except as noted, the 2025 laws did not amend any of the statutory provisions summarized below.
1. SB 442 (2019), WVR’s project
In 2019, the Indiana legislature adopted Senate Bill 442, which authorized the establishment of “a carbon sequestration pilot project:
“(1) that will: (A) capture carbon dioxide at the proposed ammonia plant to be located at 444 West Sanford Avenue, West Terre Haute, Indiana; and (B) inject carbon dioxide underground through one (1) or more injection wells pursuant to a Class VI well permit issued by the United States Environmental Protection Agency; and
“(2) that will employ the underground storage of carbon dioxide as an alternative to releasing the carbon dioxide into the air.” Sec. 14-39-1-3.5(a).
SB 442 was thus passed to authorize a specific carbon dioxide sequestration project that would capture carbon dioxide at WVR’s facility at a specific address in Terre Haute and then store it underground.
The bill did not authorize any other carbon sequestration project in Indiana.
SB 442 also provides that if the operator of WVR’s project is not able to reach an agreement with a landowner to acquire the landowner’s portion of the pore area, then the operator of the project can exercise the power of eminent domain to acquire the landowner’s portion of the pore space.
That right, however, is subject to a condition that the operator must first secure approval of landowners who own at least 60% of the pore area to be used to store the carbon dioxide. If the operator reaches a 60% approval rate, the operator can then acquire the balance through the use of eminent domain. See Sec. 14-39-1-7 (b), and Sec. 32-24-5-2 (f) and 32-24-1.
A final section of the pilot project law provides, “The legislative council is urged” to assign a study committee the task of studying the geologic storage of carbon dioxide,” including seven specific topics. This section, however, did not state the purpose of any “pilot,” and it did not require that any study be done. The section expired on December 31, 2019, five months after the effective date of the law.
The Citizens Action Coalition, a non-profit consumer and environmental advocacy organization in Indiana, says on its website that the study committee was never formed. “In other words, the Indiana General Assembly never bothered to take the time to study geologic CO2 sequestration before passing legislation that enables it,” says the Citizens Action Coalition.
2. House Bill 1209 (2022), applicable to all other projects
In early 2022, the legislature adopted HB 1209, which authorized the establishment of underground storage of carbon dioxide in Indiana. It applied generally and uniformly across the state, with one exception. Section 14 specifically carved out WVR’s carbon sequestration project. IC 14-39-2, et seq.
The general law defines “pore space” to mean the rock formations that can be used as underground storage space for carbon dioxide. It provides that the underground pore space, with some exceptions, is vested in the owner of the surface property. IC 14-39-2-2 and -3.
The general law provides that if all of the owners of the pore space needed for a carbon sequestration project do not agree to allow their portion of the pore space to be used for the project, then “the department [of natural resources] may issue an order requiring the owners to integrate their interests and to develop the pore space as a proposed storage facility for the underground storage of carbon dioxide …” 14-39-2-4(b)
But before issuing such an order, the department must find that 1) the storage operator has filed a complete application for a UIC Class VI permit [this was amended by the 2025 laws], 2) the “storage operator has made a good faith effort to obtain the consent of all pore space owners located within the proposed storage facility,” 3) the “storage operator has obtained the consent of the owners of the pore space underlying at least seventy percent (70%) of the surface area above the proposed storage facility or amended storage facility,” and 4) all pore space owners “are equitably compensated.” 14-39-2-4(c).
The general law thus requires the consent of the owners of at least 70% of the surface area above the proposed pore space. And if that percentage is met and all pore space owners are “equitably compensated” and the other requirements are met, the department may issue an order requiring owners to integrate their interests and to develop the proposed underground storage facility.
The general law also provides limits on landowners’ claims alleging that the carbon dioxide migrated underground beyond the proposed boundaries of the pore area, and provides limits on claims for punitive damages. IC 14-39-2-12 (b) - (d).
The general law does not give operators of carbon sequestration projects the right of condemnation to acquire underground rock formations to store carbon dioxide.
The Citizens Action Coalition says that the bill was “primarily pushed by BP [British Petroleum] to enable their scheme to store a fraction of the enormous amount of CO2 bellowing from their refinery in Whiting.”
3. SB 451 (2023) amendment to the law for WVR’s project
In 2023, the legislature adopted SB 451, which amended the 2019 law applicable to WVR’s project.
SB 451 again makes clear that it applies only to a project that captures carbon dioxide at an ammonia plant located at a specific address in Terre Haute, which is the address of WVR’s facility. In addition, the amendment provides that the project can have a maximum of two carbon dioxide pipelines and may maintain operations only in Vigo and Vermillion Counties.
The amended Section 14-39-1-3.5(a) provides that it authorizes the establishment of a carbon sequestration pilot project that will:
“(A) capture carbon dioxide at the proposed ammonia plant to be located at 444 West Sandford Avenue, West Terre Haute, Indiana;
“(B) construct, operate, or use not more than two (2) carbon dioxide pipelines;
“(C) maintain operations only in Vigo and Vermillion counties; and
“(D) inject the carbon dioxide underground through one (1) or more injection wells pursuant to a Class VI well permit issued by the United States Environmental Protection Agency.”
At the Aug. 16, 2023, meeting in Universal, Nalin Gupta, CEO of Wabash, referred to the legislation as “our bill;” and in responding to a question, he said, “I know what I passed.”
Like the general 2022 law, the 2023 law for WVR’s project provides that title to the underground pore space is held by the people who own the surface area above. IC 14-39-1-16.
Unlike the general 2022 law, though, the 2023 law for WVR’s project does not require WVR or its subsidiary to obtain the consent of 70% of the owners of the pore space, and does not require a showing that all owners of the pore space have been “equitably compensated.” Rather, it provides a new, completely different path.
Sec. 14-39-1-17, which was added to the law for WVR’s project, provides that “before the anticipated migration of carbon dioxide,” the operator of WVR’s project shall notify the persons who own the pore space and offer to pay them an amount equal to 40% of the rental value of the surface area, as specified in the Purdue University farm survey. Payments will be required each year until the injections of carbon dioxide stop. 14-39-1-17.
WVR says in a Q & A section of its website that these payments will be about $150 per acre per year, commencing when the carbon dioxide migrates under the property and continuing until the project is complete and injections cease.
A landowner who does not accept this offer may request a nonbinding mediation. Sec. 14-39-1-18(a) and (b). If the parties do not reach an agreement in the mediation concerning “the acquisition, lease, or occupancy of the pore space,” the landowner may “pursue a civil action against the pilot project operator.” But “[a] civil action described in this subsection may be brought only under this section.” 14-39-1-18(c). (Emphasis added)
In that civil action, a court may not grant “injunctive relief or an order of possession;” and the court may not award “monetary relief that exceeds the fair market value of the pore space in Indiana.” Sec. 14-39-1-18(d).
There is an exception. “Monetary relief” is not limited in cases alleging “tangible physical injury or damage” to a person, tangible property or an animal. 14-39-1-18(e).
The 2023 law for WVR’s project does not expressly give the operator of WVR’s project authority to use pore space without obtaining the owner’s consent. But in a civil action described in IC 14-39-1-18, a court may not enjoin the operator of WVR’s project from using the pore space under a landowner’s property, and it may not enter an order of possession.
A landowner’s sole remedy may be to file suit and seek a monetary award which may not exceed “the fair market value of the pore space in Indiana.” Arguably, this provision may bar a landowner from recovering for any decline in the market value of his/her property because tons of carbon dioxide have been injected underground.
At the Aug. 16, 2023, meeting with WVR, one resident asked what WVR would do if a property owner refused to lease WVR the pore space under his or her property.
WVR’s vice president of operations Mr. Chambers said, “So the way this statute is written and stands here … trespass without damage is allowed. So, if the plume goes under somebody’s property, if there’s no damage there’s no trespass, which is a standard thing. But we are required to make offers of payments to every single landowner.”
Perhaps as a fallback, WVR retains the right of eminent domain, which requires having the approval of landowners who own 60% of the pore space.
4. Some other differences between the laws
There are other differences between the special law for WVR’s project and the general law.
First, the general law requires an operator of a carbon sequestration project to obtain a permit from the Indiana Department of Natural Resources. IC 14-39-2-5(b), in addition to obtaining a Class VI permit from the U.S. EPA. The law for WVR’s project does not require the operator to obtain a permit from the department.
Second, the general law provides that an operator of a carbon sequestration project may apply for a “certificate of project completion.” To obtain the certificate, the operator must show, among other things, that the carbon dioxide in the pore area is stable. If the certificate is issued, the state “will assume ownership of and responsibility of the storage facility,” and assume “any potential liability associated with the storage facility.” IC Sec.14-19-2-13. These provisions in the general law would provide protection for landowners and the general public in the future, if the operator goes out of business or has minimal financial resources.
A provision in the law for WVR’s project says the State “may” take over ownership of the carbon dioxide and the rock formations after the project is closed, but there is no requirement to do so, and no requirement that the State assume liability after the operator stops injecting carbon dioxide int the ground. IC 14-39-1-14.
C. Special legislation under Indiana’s constitution
1. Art. IV, Sec. 22 of the Indiana Constitution
Article 4, Section 22, of Indiana’s Constitution provides, “The General Assembly shall not pass local or special laws concerning 15 specific subjects, including “Regulating the practice in courts of justice.”
A special law “pertains to and affects a particular case, person, place, or thing, as opposed to the general public.” Municipality of City of South Bend v. Kimsey, 781 N.E. 2d 683 (Indiana Supreme Court 2003).
Subsections 14-39-1-18(d) and (e) appear to be both special and local laws in that they apply only to WVR’s project in Terre Haute and only to pore areas in Vermillion and Vigo counties. And, these subsections provide that in certain landowner lawsuits, a court may not grant injunctive relief or an order of possession and may not grant monetary relief that exceeds the fair market value of the pore space.
One issue is whether Secions14-39-1-18(d) and (e) fall within the prohibitions of Article IV, Section 22 of the Constitution. If they do, they may be unconstitutional.
2. Art. IV, Sec. 23 of the Indiana Constitution
In addition, Article 4, Section 23 of the constitution provides, “In all cases enumerated in the preceding section, and in all other cases where a general law can be made applicable, all laws shall be general, and of uniform operation throughout the State.”
a. The City of Hammond case
In City of Hammond v Herman & Kittle Properties, Inc. 124 N.E.3d 46 (2019), the Indiana Supreme Court considered whether a law that allowed the cities of Bloomington and West Lafayette to charge local landlords an amount in excess of $5 to register rental properties (the Fee Exemption) violated Art. 4, Sec. 23 of the Indiana Constitution. All other localities in Indiana were restricted to charging only $5.
The Court recognized that the Fee Exemption was “special legislation,” because it only applied to two cities and not to any other localities in the State.
That, however, did not end the inquiry under Section 23. The Court, after an extensive review of many of its prior decisions on the subject, said, “a special law complies with Article 4, Section 23 when an affected class’s unique characteristics justify the differential treatment the law provides to the class [citations omitted]. But a special law violates Article 4, Section 23 when there are no unique circumstances that warrant the special treatment – meaning that a general law could be made applicable [citation omitted].”(Opinion, pp. 20-21)
The Court also considered the burden of proof. Initially, “the burden is on the proponent [of the special law] to show that a general law can’t be made applicable. See id. This requires the legislation’s proponent to clear a low bar by establishing a link between a class’s unique characteristics and the legislative fix.” (Opinion, p. 21)
The Court considered three justifications proffered by Bloomington and Lafayette. One justification offered was that Bloomington and Lafayette had the highest percentage of renter-occupied housing units in Indiana, and these percentages give landlords unequaled control over the supply of housing. The court found that the percentages of renters in Bloomington and Lafayette were about 67% and the percentages in certain other cities were in the range of 44% to 58%. The Court said the differences “are not defining enough to justify the differential treatment.” (Opinion, p. 22)
A second justification was that Bloomington and Lafayette were homes to the University of Indiana and Purdue University which had high percentages of students who are “often unsophisticated first-time renters.” The Court held that there were other large universities in other cities and so the proponents failed to show “a unique characteristic that warrants special treatment.” (Opinion, p. 23)
Third, the proponent argued that Bloomington and Lafayette had “uniquely long histories of regulating landlords in the rental-housing market.” But the court said the proponent failed to show that their programs were unique, noting that several other cities, Hammond and the City of Goshen, had long-running programs. (Opinion, p. 23)
The Court held, “The justifications set forth by Herman & Kittle demonstrate nothing more than a ‘generalized uniqueness’ in Bloomington and West Lafayette. … In other words, while there are characteristics of Bloomington and Lafayette that may be uncommon or rare across the state, that is not enough; rather, ‘there must by unique characteristics that justify the particular piece of legislation.’ Id. [emphasis added by the Court]. There is no evidence, for example, that either Bloomington or West Lafayette is facing a fiscal issue that would justify charging higher amounts for rental-registration fees than every other municipality in the state.” (Opinion, p. 24)
The Court further noted that “For two of the proffered ‘unique characteristics.’ Herman & Kittle failed to establish a link between those characteristics and the Fee Exemption’s preferential treatment. Specifically, Herman & Kittle didn’t explain why populations of young, unsophisticated renters or long-running rental fee programs justify allowing Bloomington and West Lafayette to charge rental fees over $5.” (Opinion, p. 24)
The Court held that “a general law can be made applicable, which means the Fee Exemption is unconstitutional special legislation.”
b. What unique characteristics justify special treatment of WVR?
The 2023 law, IC 14-39-1 et seq., applies only to WVR’s carbon sequestration project, and it only authorizes operations in Vermillion and Vigo counties.
Under City of Hammond, it appears that the proponents of the law for WVR’s project must demonstrate there are unique characteristics about the project that justify treating it differently from all other carbon sequestration projects in the state and that justify treating landowners in Vermillion and Vigo counties differently from landowners everywhere else in the state.
And, the unique characteristics of WVR’s carbon sequestration project must justify all aspects of the special treatment given to WVR. For example, what are the unique characteristics of the project that justify:
a) not requiring WVR and its subsidiary to obtain a permit from the Department of Natural Resources?
b) not requiring WVR and its subsidiary to obtain the approval of landowners who own 70% of the pore space?
c) not requiring WVR and its subsidiary to demonstrate that all landowners of the pore areas are equitably compensated?
d) precluding landowners of the pore areas from obtaining injunctive relief or an order of possession in certain lawsuits?
e) eliminating a landowner’s claim for diminution of property value?
f) giving WVR or its subsidiary the power of eminent domain?
The author asked WVR by email on April 22 to comment on whether there was anything unique about WVR’s project that justified its special treatment in IC 14-39-1, et seq. WVR did not respond with any comments for the record.
By email dated April 24, The author also asked three sponsors of SB 451 (2023) to provide the specific reasons why WVR and/or its subsidiary are treated differently than other possible operators of carbon sequestration projects throughout the state. They did not provide an answer to the question or provide any comments about the project.
By email dated April 26, the author also asked the lead author of SB 451 (2023), what were the unique characteristics of WVR’s project that justified treating it differently in IC 14-39-1, et. seq.? He did not respond.
c. What about being a pilot?
Proponents might claim that WVR’s project is a “pilot” and that this gives it special status. But the provisions of Art. IV, Section 23 of the Indiana Constitution do not expressly exempt pilot projects.
And assuming that being a pilot project could under certain circumstances be a unique factor that justifies different treatment for the project, the proponents of the pilot project law would arguably need to establish what the specific purpose of the pilot is, and how that purpose justifies each aspect of the special treatment provided to WVR’s project.
3. Professor Zoldan’s comments
The author asked Evan C. Zoldan, Professor of Law and Director of the Legal Institute of the Great Lakes, at the University of Toledo College of Law to comment on whether or not the law dealing with WVR’s carbon sequestration project constituted special legislation and is prohibited under Art. 4, Sections 22 and 23 of the Indiana Constitution. Professor Zoldan is the co-author of a case book on state and local government, in which he authored the chapter on special legislation. He has also published articles on special legislation in several law reviews.
Professor Zoldan, said, “After looking at the statutes and some news reports about the sequestration program, I think that you are right to suspect that the Indiana Constitution's special legislation clauses might be implicated by the program. As you note, statutes that single out or pertain to a particular case, person, place or thing, as opposed to the general public, are considered special legislation. This includes statutes that name particular municipalities for special treatment (sometimes called local legislation).
“It is true that statutes are permitted to single out locations when those locations have some unique need that justifies unique treatment. The Indiana Supreme Court has noted that the constitutionality of special legislation hinges on the uniqueness of the identified class and the relationship between that uniqueness and the law. That is, even a targeted statute is constitutional if the class targeted has unique characteristics that justify the differential treatment the law provides to that class. But when there are no unique characteristics of an affected class that warrant the special treatment—meaning that a general law could be made applicable—the targeted statute is not lawful.
“Here, 14-9-1 authorizes the establishment of a carbon sequestration pilot project at a single location in two particular, named counties, Vigo and Vermillion. So, a court reviewing this statute ought to ask whether there is some unique feature of these counties or this location that would allow the targeted nature of the statute. If not, then it would appear that the statute is impermissibly special. This is a fact-specific inquiry and is usually the hardest part of the special legislation analysis and in this case might require knowledge of the geology and topography of the region.
“Another way of saying the same thing is that, if there is nothing relevantly unique about the location subject to the targeted law, then a general law could be made applicable. If a general law could be made applicable, then the special treatment of the location would be invalid under the Indiana Constitution.
“None of this is a prediction about what a court will do, or legal advice about what any affected individuals should do. But I do think you are correct to flag the sp ecial legislation provisions in connection with the sequestration program.”
The author likewise states that nothing in this article is legal advice or other advice.
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For more information about the WVR’s project, here is a link to a question and answer section on WVR’s website:
https://www.wvresc.com/faq/
And here is a link to the website of Citizens Action Coalition:
https://www.citact.org/wvr